Regulatory types like documentation.  You have already applied several
techniques to your design process that were intended to assure the requested
level of functionality.  You claim to use only documented APIs, do not
depend upon OS internal structures, and have tested a wide variety of actual
hardware.  The first thing you should do for the regulatory people is to
write down this list of things you've already done.  Next you should make a
list of things that could go wrong, both things you control and, more
importantly, things you do not control.

As a technical problem, you can only be held accountable for your own
efforts.  If you wish to act as an insurance business, you can accept the
responsibility for what others (like Palm) do, even though you have no
control over their actions.

The highest quality software that I've seen was written by one
individual/group, and studied by another.  The function of the second pass
over the code was solely to audit it.  Done right, this is a valuable
process for everyone.  Done wrong, it can be a nit picking argument over the
spelling of comments, indentation style, and other aspects of a program that
do not relate to the externally visible function.  Another technique I've
seen used effectively is what I call grooming.  Code is revised to improve
coherency, without necessarily changing the actual results.  I'm much more
impressed by the results of code audits than by the results of black box
testing.

The quality of the code needs to be matched to the quality requirements of
its application.  Code that controls medical life support devices clearly
needs more attention than game or entertainment software.  You need to
understand the value system of those imposing the regulations.  Are they
trying to assure a level of quality, or simply on an ego trip to demonstrate
their ability to control you?  If they really want quality, demonstrate that
you consider them a valuable part of your team.  If they're just SOBs, flood
them with details that they will have to wade through.



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